Anatomy IT (AIT) asks Centers for Medicare and Medicaid Services (CMS) to consider your experience with quality reporting in comments submitted on the 2026 Quality Payment Program (QPP) proposed rule. See our previous blog for a summary of the proposed changes to the QPP in 2026. You can also refer to our previous blog on the Requests for Information (RFIs) included in the 2026 QPP proposed rule.
Quality Payment Program Comments
In AIT’s response to the 2026 QPP proposed rule, we focused on problems that our clients currently face under MIPS and flagged foreseeable challenges that could be caused by the proposed changes.
In the Quality section we:
- Continued to advocate for our specialty and subspecialty clients.
There are a decreasing number of relevant measure options, particularly at the subspecialty level.
- We emphasized the need for a comprehensive set of specialty- and subspecialty-specific measures to accurately reflect the quality of care delivered by these physicians.
In the Improvement Activities (IA) section we:
- Advocated for small practices by encouraging CMS to maintain special scoring in future years.
- Opposed CMS’ proposal to remove the eight IAs that were suspended this year. We asked CMS to reinstate these IAs as their suspension violated existing CMS regulation and created instability for MIPS physicians.
In the Promoting Interoperability (PI) section we:
- Supported CMS’ proposal to suppress (not score) the eCR measure for 2025 due to the CDC’s pause in onboarding new healthcare organizations.
- Supported CMS’ update to the Security Risk Analysis (SRA) measure with an important modification.
CMS’ proposal* would *require clinicians to attest to implementing security measures during the performance year, in addition to conducting the SRA.
- Our requested modification: We asked CMS to extend the timeframe for implementation for practices that conduct their SRAs in the final quarter of the performance year.
In the Cost section we:
- Thanked CMS for proposing a two-year informational-only feedback period for new cost measures. This will allow time to evaluate and refine the measures before they impact clinician scores.
- Enthusiastically supported CMS’ proposed change to the attribution for the Total Per Capita Cost (TPCC) measure.
The proposed change would exclude advanced practice nonphysician practitioners (NPs/PAs/CCNSs) from TPCC if all other clinicians in the group are excluded based on the specialty exclusion criteria.
- This is a *huge *win for specialty practices that have been unfairly attributed the measure under the current approach.
- This would ensure that only clinicians directly responsible for the care of a condition would be assigned the associated costs, thus avoiding a repeat of the broad and inappropriate attribution that occurred with the 2022 Diabetes Cost Measure.
- This would also mirror the exclusions in the TPCC measure.
*In the **MIPS Value Pathways (MVPs) section we:*
- Supported CMS’ proposal for groups to self-attest to their specialty composition during MVP registration, rather than CMS determining specialty based on two-digit specialty codes.
- Supported the proposal to exclude small multispecialty practices from having to divide into subgroups beginning in 2026.
- Advocated for increased measure choice in MVPs, particularly for subspecialists.
- Responded to CMS’ request for feedback on the use of Medicare procedural codes:
We cautioned CMS *against *using claims data to determine a clinician’s specialty in the future, as the information provided by claims has significant limitations and may not accurately depict the clinician’s true focus of care.
- This would further limit clinician choice and lead to specialists being forced to choose measures that may not be relevant to their practice.
- In the proposed rule, CMS reiterated their desire to “sunset” traditional MIPS and make MVPs mandatory as early as 2029.
- We believe a fee-for-service model will always be both valuable and necessary. Moreover, we do not believe that MVPs will be applicable to specialists in the timeline CMS is anticipating.
Next Steps
- Share this information with your colleagues.
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- If you are an Anatomy IT client, contact your MIPS Expert if you have any questions.
- If you are not an Anatomy IT client, contact us to learn more about our MIPS Success Plan and to reap the rewards of our combined decades of experience.
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Written By: **Sarrah Hakim, MHSA
About the Author: Sarrah is a Manager of Health Policy at Anatomy IT.